ML19261B448
| ML19261B448 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/08/1979 |
| From: | CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | |
| Shared Package | |
| ML19261B439 | List: |
| References | |
| NUDOCS 7902230128 | |
| Download: ML19261B448 (12) | |
Text
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3 INTERIM REPORT ON SIGNIFICANT DEFICIENCY S & M CONSTRUCIOPS, ETC.
QUALITY ASSURANCE PROGRAM BREAKDCWN RIDARDING COI"IROL OF S & M SUBCCNTRACTOR, THE HALVORSEN BOILER & DIGINEERHIG CO.
PERRY NUCLL PCWER FIANT, UNITS 1 AND 2 DOCIGT NOS. 50-WO; 50-W1 THE CL WmID ELECTRIC ILLUMINATHIG CQ4PANY February 8, 1979
?80223o pct,
t INTERIM REPORI' CN SIGNIFICANT DEFICIEICY DESCRIPTION OF DEFICIEICY A.
PR03 RAM DEFICIETCIES Introduction Documented evidence is available which is indicative of a breakdown in the S & M Constructors, Inc.'s (S & M) Quality Assurance Program in the areas of:
Criterion II, Quality Assurance Program; Criterion IV, Procure-ment Document Centrol; Criterion V, Instructions, Procedures, and Drawings; Criterion VII, Control of Purchased Material, Equipnent, and Services; Criterion IX, Control of Special Processes; and Criterion X, Inspection.
A brief chronology of events concerning S & M Constructors' QA Program and Site Organization's related activities is as follows:
Chronology August 22, 1977 - Audit No.10 - This audit of S & M was perfomed to evaluate their QA Program in regards to Criterion VII, Control of Purchased Material, Equipment, and Services. Nine findings were issued as a result of this audit.
October 10 and 11,1977 - Audit No. 20 - Audit No. 20 was performed on S & M Constructors, Inc. and their subcontractor, The Paterson-Leitch Co. covering Criterion VII. Four findings were issued as a result of this audit.
November 15, 1977 - Stop Work Notification (SW) 77-4 and Nonconfordance Report (NR) CQA 014 - SWN and acconpanying NR were issued due to problems witl' welding and radiopaphy at Paterson-Leitch.
December 13, 1977 - Audit No. 35 - This audit consisted of a review of the S & M QA Program as it related to The Halvorsen Boiler & Engineer-ing Co. (HB&E). The following 10CFR50, Appendix B Criteria were covered by this audit:
I, II, IV, V, VII, IX, X, XVII, and XVIII.
Eight findings were issued as a result of this audit.
January 11, 1978 - Release for Stop Work Notification 77-4 was issued.
February 10, 1978 - Stop Work Notification CQA 78-4 and Corrective Action Request (CAR) Oh36 - SW and associated CAR were written concerning subcontractor control, but were not issued due to adequate documen-tation cf the cited condition in an audit report and an acceptable response to audit finding.
INTERIM REPORT CN SIGNIFICANT DEFICIENCY DESCRIPTIGI CF DEFICIENCY - A Page 2 February 14, 1978 - Audit No. 53 - This audit was perfomed to evaluate S & M Constructors' QA Program in the area of Criterion VII as applied to peabody Testing Services. Four deficiencies were noted during this audit.
February 15, 1978 - Stop work Notification CQA 78-5 and Corrective Action Request 0437 - This SWN and associated CAR vere issued due to deficiencies noted in Audit No. 53.
February 20 and 21, 1978 - Audit No. 55 - This audit consisted of a review of S & M Constructors' QA Program against thts requirements of all eighteen criteria of 10CFR50, Appendix B.
Iifteen findings were issued involving twelve of the eighteen cri;eria. This audit was perfomed utilizing the Standard Review Plan as a checklist.
March 10, 1978 - Release for Stop Work Notification CQA 78-5 was issued.
April 6,1978 - Audit No. 70 - This audit was perfomed to evaluate the effectiveness and inplementation of the S & M QA Program in the area of Criterion VII as it applied to Halvorsen Boiler & Engineering.
Three findings were issued as a result of this audit.
April 17, 1978 - Audit No. 74 - This audit was perfomed as a follow-up to Audit No. 70. ' Cne finding and one Nonconfomance Report were issued as a result of this audit. The NR was issued to GAI Enginee'r-ing.
September 27 and 28, 1978 - Audit No.162 - This audit was perfomed as a follow-up to Audit No. 55.
November 16, 1978 - CQC inspection trip was nade to HELE's shop. Defi-ciencies were noted.
(Surveillance Inspection Report C-627).
November 17, 1978 - Trend analysis of S & M Nonconfomance Reports was conpleted. A negative trend at HELE was identified.
November 28, 1978 - An immmnunced visit to HE&E's facility was nade by representatives of Contract A+,inistration, Nuclear Engineering Department (NED), Resident Design Engineering, and Construction Quality Engineering (CQE). Result of this visit was consensus agreenent by all representatives of the Site Organization that significant problens existed at Halvorsen's shop.
Novenber 29, 1978 - As a result of the previous day's visit to Halvorsen, Nonconfornance Report CQA 035 was iscad. This NR identified nunerous velding deficiencies on the Intake Structure. Stop Work Notification CQA 78-12 was issued concurrently with NR CQA 035.
INTERLt REPORT CN SIGNIFICANT DEFICIENCY DESCR1PTICH -OF DEFICIENCY - A Page 3 Dece=ber 13, 1978 - PNFP Review Board reviewed S & M's response to Im CQA 035 Response was rejected since S & M refuted the existence of =adority of deficiencies identified by Site Organization personnel.
December 14, 1978 - S & M submitted revised response to Im CQA 035, Rev. 1 S & M stated in this response:
" Items 1, 2, 3, 4, 5, 6, 7, and 9 (of NR cQA 035) are not identified as deficiencies by the S & M QA Element..."
December if,1978 - A meeting was held between the Site Organization and S & M, including their subcontractors. The purpose of this meeting was twofold:
(a) to discuss in detail each deficiency noted in Im ORA 035, and (b) to discuss the six conditions i= posed by the Site Organization for release of Stop Work Notification CQA 78-12.
The six conditions are as follows:
1.
Satisfactory resolution of Im CQA 035 2.
Satinfactory resolution of NR 29-18.
3.
Date Certain for ECN 1359-29-45 (ECN modifies welding and NDE requirements for SP-29).
4.
Agree to additional radiographic testing of Intake Structure welds.
5 All welding and NDE procedures used on Intake Structure shall' be submitted to Site Organization for approval.'
6.
Agreement per provisions of SP-708 for a Site Organization Resident QC Inspector at Halvorsen.
Subsequent to this meeting, NR CQA 035, Rev.1, was rejected by the Site Organization.
Decc=ber 20, 1978 - Continuation of meeting of December 19, 1978 was held at Halvorsen's shop. - Purpose of this continuation was to demonstrate the presence of deficiencies noted by the Site Organi-zation and refuted by S & M.
Mr. S. Hopkins, consultant to S & M, concurred that deficiencies noted by the Site Organization did, in fact, exist and were generic in nature,'and not W ited to a few specific welds.
Dece=ber 21, 1978 - S & M submitted Revision 2 to NR CQA.035 S&M also submitted welding and NDE procedures which were in use by their subcontrccLars. This submittal for Site Organization review was one of the previcusly identified conditions for release of Stop Work Notification 78-12.
January 4,1979 - CQE ce=pleted review of all NDE and Inspection procedures submitted by S & M.
All procedures were totally inadequate for work and were dispositioned "Not Acceptable."
E ERIM PSPORT GT SIGNIFICANT DEFICIETCY DEJCRIP.ICU OF DEFICIHiCY - A Page 4 January 5,1979 - FNPP Review Board rejected NR CQA 035, Rev. 2; NR 29-18, Rev. 2; NR 29-39; NR 29-40; NR 29-41; and NR 29-42. The last four NR's were issued to document additional deficiencies at Halvorsen.
Deviation Analysis Report (DAR) initiated this date. This date is Date Certain for ECN 1359-29-45 (see Item 3 under December 19, 1978).
January 12, 1979 - Telephone can between J. M. Lastovka (CEI) and K. Naidu and J. KonkHn (NRC Region III) to discuss potential Significant Deficiency in S & M's QA Program.
January 16, 1979 - S & M submitted response to NR 29-18, Rev. 3, and NR 29-40, Rev.1, without required weld procedures. Review pending receipt and review of weld procedures.
January 17, 1979 - Selection of audit team and audit date for Program Review audit of S & M Constructors. Received revised NDE procedures.
January 18, 1979 - Site organization received qualification dccumentation for Quality Testing NDE personnel (subcontractor performing NDE. at Halvorsen shop) from S & M.
January 19, 1979 - Site organization received Quality Testing's ultrasonic, radiography, and magnetic particle procedures from S & M.
January 26, 1979 - Site organization ce=pleted review of resub=itted Quality Testing NDE procedures which were previously dispositioned as not acceptable. Current dispositions range from " Conditional Accept" to " Accept."
Detailed S-7 of Program Deficiencies Initial concerns over quality of work at Halvorsen Boiler & Engineering Co. were stimulated by hardware ' deficiencies identified on various Nonconfor=ance Reports and audit reports referenced in Chronology, above.
Further investigation by Site Organization personnel led to the conclusion that major deficiencies were present in the S &.M Constructors' Quality Assurance Program. In fact, the number of hardware deficiencies, and the magnitude thereof, were directly related to the program deficiencies in that the hardware problems were either not identified or were not recognized as deficiencies by the. contractor.
Specific program deficiencies identified are as fonows:
1 loCFR50, Appendix 3, Criterion II, Quality Assurance Program, states in part, ".... the Quality Assurance Program shall provide control over activities affecting the quality of the identified (as safety-related) structures, systems, and cc=ponents..." and "... rnnnge-ment of other (than applicant) organizations participating in the
INTERIM REPCRT ON SIGNIFICANT DEFICIENCY DESCRIPfION OF DEFICIENCY - A Page 5 Quau ty Assurance Program shall regularly review the status and adequacy of that part of the Quality Assurance Program which they are executing."
Contrary to the above, S & M Constructors' Quality Assurance Program was deficient in that:
(a) S & M's quality Assurance personnel failed to identify numerous significant noncompliances with specifi-cation and code requirements in the areas of welding and weld inspection prior to identification by Site Organization personnel, and; (b) S & M QA personnel failed to recognize the above-referenced noncompliances as deficiencies after identification by the Site Organization. The latter deficiency is substantiated by the S & M responses to Nonconformance Report CQA 035, Rev. O and Rev.1, and statements made in the December 19, 1978 meeting (reference Minutes.
of Meeting).
2.
10CFR50, Appendix B, Criterion II, Quality Assurance I;ogram, states in part, "... the program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and mintained..." and "... Manage =ent... shall regularly review the status and adequacy... of the Quality Assurance Program..."
Contrary to the above, S & M Constructors' QA Program is deficient -
in the area of personnel qualification and certification in that:
(a) S & M's QA Prog *as does not address qualification and certification of welding inspectors; and (b) Site Organization has verified that certain data utilized in the certification of S & M's welding inspector was erroneous.
3.
10CFR50, Appendix B, Criterion IV, Procurement Document Control, states in part, " measures shall be established to assure that applicable regulatory requirements, design bases, and other require-ments which are necessary assure adequate quality are suitably included or referenced in me documents for procurement of material..."
~
Contrary to the above, S & M Consmictors did not include or reference all applicable requirements of Specifiestion SP-29-4549-00 on a purchase order for ASTM A-441 steel to be used in the Intake Structure.
4.
10CFR50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states in part, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...
(which) *til include appropriate quantitative or qualitative accep-tance criteria for decemining that important activities have been satisfactorily acco=plished."
IIITERIM REPORT CN SIGNIFICANT DEFICIENCY DESCRIPfIGN CF DEFICIENCY - A page 6 Contrcry to the above, S & M Constructors' Visual Welding Inspection procedure (QCP-107, Rev. 0) was deficient as it lacked sufficient detail and guidance for perfo: ming required inspections, did not contain acceptance criteria for all inspections, and did not provide adequate documentation of inspection results.
5 10CFE50, Appendix B, Criterion VII, Control of Purchased Material, Equiprent, and Services, states in part, "=easures shall be estab-lished to assure that purchased material, equi;=ent, and services, whether purchasad directly or through contractors and subcontractors, confom to the procurerent documents... Docu=entary evidence that
=aterial and equiprent conform to the procurement require =ents shall be available... and shall be sufficient to identify the specific require =ents... =et by the purchased =aterial and equipment."
Contrary to the above, S & M Constructors' QA Progra= vas deficient in the area of subcontractor control. This deficiency is substantiated by the Site Organization review of in-place procedures belonging to S & M's subcontractors. Each of these procedures reviewed was found to be inadequate and was dispositioned "ITot Acceptable." This review and disposition was considered to be evidence of inadequate review by S & M.
6.
10CFR50, Appendix B, Criterion IX, states, "=easures shall be
. established to assure that special processes, including velding, heat treating, and nondestructive testing are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Contrary to the above, S & M Constructors' control of special processes is deficient, as demonstrated by the following:
(a) Joint configurations represented by welding procedures sub-4tted by S & M are not shown on Halvorsen Boiler & Engineering's -
(IEEE) shop drawings.
(b) Joint configurations shown on the HB&E shop drawings are not represented by velding procedures.
7, 10CFR50, Appendix B, Criterion X, Inspection, states in part, "a program for inspection of activities affecting quality shall be established and executed by or for the organization perfoming the activity to verif'y conformance with the documented instructions, procedures, and dravirgs for accomplishing the activity...
Ermirmtions,. =easure=ents, or test of material or products processed shall be perfomed for each work operation where necessary to assure quality."
INTERr4 REPORT CN SIGNIFICART DEFICIENCY DESCRIPTICN CF DEFICIENCY - A Fage 7 Contrary to the above, S & M Constructors' visual velding inspection was inadequate as demonstrated by the number of obvious deficiencies identified by Site Organization personnel subsequent to 5 & M's inspection.
B.
HARDWARE DEFICIENCIES Introduction Hardware deficiencies existent in work perfor=ed by Halvorsen Boiler &
Engineering were primarily identified in Nonconfor=ance Report CQA 035 S-a~/ of specific deficiencies identified are as follows:
1 I= proper veld joint fit-up. Root openings vary frcs 0" to 3/4" (top to bottom - 48" approxinate). Documentation reviewed indicated this problem had been documented and identified by the contractor on two veld joints (for excessive gap once). Subsequent visual examination by Site Organization personnel revealed this condition existed on other velds which were tacked and aligned (both excessive and inadequate gap).
2.
No pre-veld clenning had been performed. Slag and oxidation from flame cutting were present.
This condition also existed on a joint which was in-process of being velded on Novenber 28, 1978. Slag and oxidation evident was not limited to that left frca flame cutting. Exc=ination of in-process velding revealed indications of improper preeleaning and inadequate cleaning between veld passes. This condition appears to be a generic problem with all velds.
3.
Finished weld profiles do not meet the requirements of AWS Dl.1.
Exnmination of ec=pleted veld profiles revealed that profiles range frcm below surface of the base material to reinforcement, which exceeds the requirement of AWS D1.1.
Previous inspections by Site Organization revealed weld profiles of filler pcsses, which would indicate improper velding techniques such as high veM metal build-up or repe-type bead. This condition is inherent with all velds.
4 Visual examination of various fillet and full penetration velds revealed:
(a) excessive porosity; (b) undercut; (c) slag pockets; (d) incenplete fusion; and (e) poor tie-ins to tacks. Subsequent inspection revealed cracks observed visually on surface of welds.
Conditions noted above were observed on completed and in-process velds.
IFTERIM REPCRT Cti SIGNIFICANT DEFICIENCY DESCRIPTICN CF DEFICIENCY - 3 Page 8 5.
Tack welds used for fit-up are not being tapered at their starting and stopping edges prior to incorporating them into the root pass.
This problem was originany identified on Nonconfomance Report CQA 023 as a result of CQE Audit No. 74, dated April 05, 1978. As documented in the body of the. report, this condition would not exist if the tack welds had been removed as explained to the auditors by the subcontractor. To date, satisfactory resolution to Ncncen-formance Report CQA 023 has not been obtained. However, a meeting on January 30, 1979, between CQE and GAI Engineering resulted in agreement for satisfactory resolution.
6.
Where joints have been fit-up and tack welded, and the carbon steel backing strip is welded in place, there is no penetration of the tack weld into the backing strip. On the vertical velds connecting the outer liner of Intake Structure No. 2, the backing strips were placed after the tack welds were made in the weld groove. Further investigation involved cases where the bach"5 strip was tacked in place frem the veld groove side. This practice is contrary to normal welding techniques. (NOTE: Back side of weld joint was accessible for proper tacHng of the bacHng strip.) This ccndition could be identified only for those welds for which root pass had not been made.
7.
Weld bead width (weave) is as =uch as two inches or more. At the request of consultants for S & M Constructors, Inc., this matter was referred to AWS for interpretation. This condition is prevalent in all welding..
8.
The approved weld joint design for the top plate welds is not being used.
(Reference Halvorsen Shop Drawing G850-1, Rev.19.) Subsequent investigation has also revealed that joint configurations shown on drawings do not correspond with veld procedures sub=itted.
9 Visual exwnation reveals an appearance of copper deposits in the weld metal connecting the outer liner plates to the stiffener.
One veld had been ec=pleted and one prepared for welding using copper banHag bars without Engineering approval.
lo.
The specification (SP-29-4549-oo, Rev. II) required material to be in accordance with ASE4 A W1-74 The purchase order did not specify the applicable edition of ASE4. The material supplied to a later edition of ASH 4 (AST4 awl-75) did not contain the mandatory require-ment of transverse bends. This should have been added by purchase order as a supplemental reqairement. AH AS24 AS1 material for structures associated with SP-29 4549-Oo are affected.
.11 Prior to the above hardware deficiencies, other deficiencies, such as la= ell e tear between adjacent welds, had been identified by the contractor.
INTERr4 REPORT CN SIGNIFICA';T DEFICIETCY
/dlALYSIS CF SAFET? IMPLICATIGIS Page 9 ANAIYSIS OF SAFETY BEICATIGTS A.
PRQlRM4 DEFICIETCIES The safety implications of a quality Assurance breakdown are difficult to evaluate as an entity. In the specific case addressed in this report, the Qua.lity Assurance Program deficiencies are directly related to hardware deficiencies identified and discussed in other sections of this report. Because of this correlation, and other evtduations discussed under the " Corrective Action Taken" section, the safety implice.tions of the effects of the Quality Assurance Program breakdown will be identical to the safety implications of the hardware deficiencies. The hardware deficiency analysis is given in the following section of this report.
B.
HARDWARE DEFICIEICIES Safety i=plications of hardware deficiencies are currently being evaluated by Engineering. Results of this evaluation are not available at this time; however, co=plete results of the analysis of safety implications of the hardware deficiencies will be included in the Final Report to be subnitted by June 1,1979 CORREC'f1VE ACTIM TAKEN A.
PROGRAM DEFICIETCIES Corrective actions taken or to be taken on identified program deficiencies are presented in the same order and format as in the " Detailed S-4my of Program Deficiencies."-
Details of corrective action are as follows:
1 S & M Constructors' failure to recognize the identified hardware deficiencies as such has been corrected as de=enstrated by S & M's revised response to Nonconfor=ance Report CQA 035, Rev. 2, as well as by additional Nonconfor=ance Reports written by S & M to further dccument weld deficiencies. This change in the attitude of S & M is further demonstrated by statements made by Mr. S. Hopkins of Industrial Inspection Industries, Inc., 'a consultant to S & M at a meeting held at Halvorsen Boiler & Engineering's facilities on December 20, 1978, wherein Mr. Hopkins agreed that the deficiencies identified by Site Organization did, in fact, exist and were generic in nature and not limited to a specific weld.
Corrective action taken by Site Organization in this area consists of arrangements for a full-time Site Organization Level II Weldir4 Inspector to be present in Halvorsen's shop when Stop Work Notification CQA 78-12 is released.
INTERIM PIPCRT GT SIGNIFICANT DEFICIENCY CCAP2CTIVE ACTIGi TXGI - A Page 10 2.
No corrective action has been taken by S & M Constructors to date.
Site Organization corrective action taken in this area consists of written direction to S & M that a re-evaluation of the qualifications /
certificaticus of their (S & M's) welding inspector is to be submitted to the Site Organization for review and evaluation prior to any further utilization of that inspector on safety-related work for the perry nuclear Power Plant.
3.
This deficiency has also been identified on Ncnconfomance Reports CQA 035 and 29-42.
Corrective actions have been specified on 'coth nonconformance reports. In addition, subsequent purchase orders have been reviewed and written ec=ents provided to S & M to preclude further recurrences of this problem.
4 S & M Ccnstructors' Visual Weld Inspection procedure (QCP-107) has been revised to adequately address the concerns cited. Additionally, Site Organization Review Board co=ents en Nonconfomance Report CQA 035, Rev. 2, require S & M to perfom and document additional inspections to compensate for the cited inadequate documentation.
5.
In order to preclude recurrence of problems in this area, site Organization has relieved S & M of the responsibility for review of special process procedures and Site Organization has assumed this responsibility.
6.
Two-fold corrective action is necessary for this item. This first action required is a ec=plete re-review of the shop drawings by Gilbert Engineering, and resolution and incorporation of the Engineering co=ments by S & M/Halvorsen. The Engineering review has been completed and the con:ments transmitted to S & M.
The second action required is a re-review of the weld procedures by the Site Organization. This re-review will be perfomed subsequent to S & M revision and resubmittal of the shop drawings and acceptance of the revised drawings by Engineering.
7.
S & M Constructors' Visual Welding Inspection procedure, QCP-107, has been revised to provide greater detail and direction for perfomance of visual inspection.
In addition, a full-time Site Organization Level II. Weld Inspector will be placed in Halvorsen's shop at the time of release of Stop Work Notification CQA 78-12.
B.
HARDWARE DEFICIENCIES Corrective actions taken or to be taken on identified hardware deficiencies are presented in the same order and femat as in the " Description of Hardware Deficiencies." No physical corrective action has been taken to date due to Stop Work Notification CQA 78-12 being in effect.
INTERr4 REPORT CN SIGNIFICANT DEFICIENCY CCP3FCIIVE ACICN TAE - B Page 11 Site organization Review Board co m ents en Ncnconfc =ance Report CqA 035, Rev. 2, placed the additional requirement that all welds, regardless of status (i.e., fit-up, in-process, or ec=plete), either be documented as acceptable or reported on nonconformance reports. A further require-ment was the verification of the acceptance status of all velds by the Site Organization.
Details of corrective action are as follows:
1 All nonconfor=ing weld fit -ups will be docu::lented on nonconformanca reports and dispositions and corrective actions will be based on specific details of each deficient veld joint.
2.
S & M Visual Weld Inspection procedure (QCP-lo7) has been revised to provide adequate procedural address to prevent recurrence of this problem. Welds will be cleaned prior to any further processing.
3 S & M procedure qCp-lo7 has been revised to address weld profiles' acceptability. All nonconforming weld profiles will be identified and dispositioned en nonconfoz=ance rescrts.
L.
All welds containing defects of the type noted in this deficiency will be identified and dispositioned en nonconfomance reports.
5.
S & M procedure QCP-107 has been revised to require the re= oval of tack welds with magnetic particle testing after removal to ensure that sound metal has been reached.
6.
Same as for item 5, above.
7.
A code interpretation has been obtained from the American Weldi$1g Society E tructural Welding Cc=mittee confiming the condition cited as an item of noncompliance with Structural Welding Code (AWS Dl.1).
Exact cerrective action is contingent upon results of Engineering's evaluation of the condition.
8.-
Corrective action for this item is the same.as that indicated for item 6 in Program Deficiency Corrective Action section of this report.
9 The use of copper backing bar is now specifically prohibited. Welds made utilizing copper baMng.bar will be ground frem the root side to a sufficient depth to ensure co=plete removal of copper contamination.
lo.
The corrective action for this item is the same as that indicated for item 3 in the Program Deficiency Corrective Action section, 11.
Specific corrective actions for other hardware deficiencies noted were given on the specific ncnconformance reports in questien.